Plaintiff's Interrogatories to Defendant (Seeking Discovery of Computerized Documents and Equipment)

UNITED STATES DISTRICT COURT

FOR A SAMPLE DISTRICT

________________________________

) Case [Form] No.: 3.4

_______________, )

Plaintiff, )

)

v. )

)

_______________, )

Defendant )

________________________________ )

Plaintiff: __________________

Defendant: ________________

PLAINTIFF’S INTERROGATORIES

TO DEFENDANT

(Seeking Discovery of Computerized Documents and Equipment)

THE FOLLOWING INTERROGATORIES are to be answered by the Defendant _______________ separately and under oath within the time permitted by law. The requested information must be provided regardless of whether it is possessed by the Defendant personally or by agents, employees, representatives or persons acting on behalf of said Defendant. If you (Defendant) or anyone acting on your behalf should discover any new information or change a position, you are obligated to supplement your answers within the time permitted by law.

1. State your name, date of birth, address and occupation; and the name, address, occupation and relationship to the parties of each individual who assisted in the answering of these interrogatories.

2. As used in this question, the term “computer storage device” includes, but is not limited to: desktop computers, notebook computers, palm pilots, mini-computers, mainframe, servers, hand held computers, any hardware used to send or receive email, any hardware used to send or receive text messages, or portable stand-alone or portable hard disk drives. Please identify every computer and computer data storage device that has been located at, or used at, the business address of ____________________, at...